Key legal question
Whether the taxpayer carried on self-employment in 2002 so that the claimed business loss was deductible
Extracted holding
No. The overall circumstances did not show an independent activity with profit motive in 2002.
Extracted reasoning
The taxpayer had no relevant business income, only one non-business insurance commission, no bank or postal accounts, no customer-generating activity, and the alleged consulting activity lacked an objective profit motive.